Staff expenditure and efficiency

FOI reference - FOI-490
Date - 25 July 2026

Request

Section 1: Executive Director / General Counsel Role Structure and Governance (Priority 1)

1. Any recorded information, business cases, organizational charts, or board minutes that clarify whether the position of Executive Director of Enforcement and Legal and the position of General Counsel exists as a single combined/amalgamated role, or whether they remain separate, distinct roles concurrently held by the same individual.
2. Copies of any operational protocols, governance frameworks, "ethical firewalls," or formal guidance documents held by the organisation that outline how the individual holding these positions must separate their decision-making duties as head of Enforcement, and head of Legal from their advisory duties as General Counsel.
3. Any recorded policies or procedures detailing the mechanism used to document which specific role or capacity (Executive Director of Enforcement and Legal vs. General Counsel) the individual is acting in when issuing formal advice, participating at Board level, or making decisions.
4. Copies of the risk assessment, conflict-of-interest assessment, and/or business case compiled prior to, or at the time of, appointing a single individual to these positions concurrently.
5. Minutes or formal records of the Board, Executive Committee, or Governance Committee meetings where the potential conflicts of interest regarding these concurrent responsibilities were discussed and approved.

Section 2: Allocation of headcount, Expenditure, and Reward (Priority 2)

1. The total number of Full-Time Equivalent (FTE) staff employed by the organisation, broken down by individual grade from Grade 3 through to Grade 15, as of 1 April 2023.
2. The total number of Full-Time Equivalent (FTE) staff employed by the organisation, broken down by individual grade from Grade 3 through to Grade 15, as of the date of this request.
3. The total annualized salary expenditure (excluding employer pension and NI contributions) for all staff combined within Grades 3 to 5, as of 1 April 2023 and as of the date of this request.
4. The total annualized salary expenditure (excluding employer pension and NI contributions) for all staff combined within Grades 6 to 15, as of 1 April 2023 and as of the date of this request.
5.  The overall percentage of staff within Grades 3 to 5 who received a bonus or non-consolidated performance-related pay reward during the most recent completed financial year.
6. The overall percentage of staff within Grades 6 to 15 who received a bonus or non-consolidated performance-related pay reward during the most recent completed financial year.

Response

Section 1

Point 1

Our published website confirms that Gaucho Rasmussen became Executive Director for Enforcement and Legal Group and Executive General Counsel in March 2026

We have identified recorded information confirming that these positions remain separate and distinct roles, notwithstanding that they are currently held by the same individual. The Senior Management Regime (SMR) shows that the responsibilities of Executive General Counsel Executive Director Legal and Enforcement are separately identified and distinct. TPR Senior Managers Regime documentation (a) Management responsibilities map and Prescribed responsibilities

Point 2

The (b) Schedule of Delegations sets out TPR’s governance framework for the exercise of regulatory, legal and operational functions. It establishes how functions are delegated, identifies which functions may be exercised by particular postholders, and sets out the principles and requirements that apply when delegated functions are exercised.

The document sets out distinct delegated responsibilities for the relevant roles. In particular:

• The Executive General Counsel, Enforcement and Legal Group is described as the chief legal adviser to the Executive Committee, responsible for oversight of legal services, provision of legal advice and support, and conduct of litigation.
• The Director of Enforcement is separately identified as being responsible for the oversight, management and approval of funding of regulatory and criminal enforcement cases and reporting on criminal enforcement matters, with a direct reporting line to the CEO on progress of criminal enforcement cases.
• The Schedule also requires decisions made under delegated authority to be taken impartially and objectively, to have regard to statutory objectives and public law principles, and to take appropriate advice, including legal advice, before acting.

Point 3

While we do not hold a specific policy or procedure of the kind described, relevant recorded information is contained in the (b) Schedule of Delegations and the (c) AG_11_BOARD_ 22_JUL_26 – Board Governance Framework Review paper presented to the Board in July 2026.”

Point 4

The (d) Senior Management Regime (SMR) Impacts Paper Feb 2026 sets out the impacts on the organisation and provides recommendations for mitigating those impacts.

Point 5

TPR board considered these issues at its meeting on 22 July.   (b) Schedule of Delegations and the (c) AG 11_BOARD_22_JUL_26 – Board Governance Framework Review paper presented to the Board in July 2026. The minutes of this meeting will be considered and approved at its next meeting.

Section 2

Points 1 and 2

Table 1 below provides a breakdown of FTE by grade as at the dates specified in Section 2 - points 1 and 2 of your request. 

Table 1

	1 April 2023	31 July 2026
Grade	FTE	FTE
3	10.81	17.8
4	36.45	32.78
5	47.5	78.42
6	155.41	192.68
7	120.25	166.67
8	163.57	160.37
9	118.31	97.47
10	70.1	57.26
11	85.49	73.73
12	53.6	35.79
13	18.87	20.83
14	13	0
15	1	0
Total	894.36	933.8

Points 3 and 4

Table 2 below provides the salary expenditure information requested at Section 2 points 3 and 4.

Table 2

	Total cost by grade		Actual annual (Pro-rated) total cost by grade
Date	1 April 2023	31 July 2026	1 April 2023	31 July 2026
Cost grades 3 to 5	£9,141,584	£12,969,176	£8,916,076	£12,666,977
Cost grades 6 to 15*	£39,739,734	£45,110,085	£38,247,451	£43,517,225
Total	£48,881,318	£58,079,261	£47,163,527	£56,184,202

*Grades 14 and 15 no longer exist, as the lower end of these pay bands has been overtaken by increases to the National Minimum Wage.

Points 5 and 6

Table 3 shows the number of staff with an end-of-year (EOY) rating that makes them eligible for bonus nomination. The figures reflect TPR's position as at 31 March 2026 and relate to performance ratings for the period 1 April 2025 to 31 March 2026. They represent the position prior to any activity associated with TPR's pay award process and before formal union negotiations have taken place, in line with Treasury pay remit guidance. As such, the figures remain subject to minor change.

Table 3

Grade	Count	Count of people receiving a bonus	Percentage (%)
Grade 3 to 5	127	35	29%
Grade 6 to 13	840	228	27%

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